121 T.C. No. 19
UNITED STATES TAX COURT
FORTUNATO J. MENDES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16032-95. Filed December 11, 2003.
P has been continuously incarcerated since June 17,
1988. For P’s 1988 taxable year, R (1) determined a tax
deficiency based upon amounts reported on information
returns as having been paid to P during that year, (2)
imposed the 10-percent additional tax under sec. 72(t)(1),
I.R.C., and (3) determined that P was subject to additions
to tax under secs. 6651(a)(1), 6653(a)(1), and 6654, I.R.C.
More than 2 years after R issued the notice of deficiency, P
filed a 1988 return in which he reported the income from the
1988 information returns and listed deductions and
dependency exemptions, which, in total, exceeded the
reported income, thereby resulting in a zero tax liability
for 1988. P now denies (1) receipt of a portion of the
income reported on his 1988 return and (2) liability for the
10-percent additional tax under sec. 72(t)(1), I.R.C. R
denies that P is entitled to any of the claimed deductions
and dependency exemptions.
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